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DHHS (NIOSH) Publication No. 2012-139, Loss of Start-Up Oxygen in CSE SR-100 Self-Contained Self-Rescuers 2012-139[1]

Apr 14, 2018

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  • 8/2/2019 DHHS (NIOSH) Publication No. 2012-139, Loss of Start-Up Oxygen in CSE SR-100 Self-Contained Self-Rescuers 2012-139[1]

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    Loss of Start-Up Oxygen inCSE SR-100 Self-ContainedSelf-Rescuers

    of Health and Human Services

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    Loss of Start-Up Oxygen in CSE SR-100 Self-ContainedSelf-Rescuers

    Robert Stein, Heinz Ahlers, Roland Berry Ann

    DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Disease Control and Prevention

    National Institute for Occupational Safety and HealthApril 2012

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    This document is in the public domain and may be freelycopied or reprinted.

    Disclaimer

    Mention of any company or product does not constitute endorsement by the National Institute for

    Occupational Safety and Health (NIOSH). In addition, citations to Web sites external to NIOSHdo not constitute NIOSH endorsement of the sponsoring organizations or their programs or

    products. Furthermore, NIOSH is not responsible for the content of these Web sites. All Web

    addresses referenced in this document were accessible as of the publication date.

    Ordering Information

    To receive documents or other information about occupational safety and health topics,contact NIOSH at

    Telephone: 1800CDCINFO (18002324636)TTY: 18882326348e-mail: [email protected]

    or visit the NIOSH Web site at www.cdc.gov/niosh.

    For a monthly update on news at NIOSH, subscribe to NIOSH eNews by visiting

    www.cdc.gov/niosh/eNews.

    DHHS (NIOSH) Publication No. 2012139

    April 2012

    SAFER HEALTHIER PEOPLE

    ii

    mailto:[email protected]://www.cdc.gov/nioshhttp://www.cdc.gov/niosh/eNewsmailto:[email protected]://www.cdc.gov/nioshhttp://www.cdc.gov/niosh/eNews
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    Loss of Start-Up Oxygen in CSE SR-100 Self-Contained Self-Rescuers

    Robert Stein, Heinz Ahlers, Roland Berry Ann

    Executive Summary

    This report describes a National Institute for Occupational Safety and Health (NIOSH) and Mine

    Safety and Health Administration (MSHA) investigation assessing the prevalence of a lack ofsufficient start-up oxygen in CSE SR-100 self-contained self-rescuer (SCSR) devices.

    The availability of sufficient start-up oxygen is critical to the performance of the SR-100. As

    part of a routine field testing program of SCSRs used in coal mines, NIOSH and MSHA detected

    two SR-100s that lacked sufficient start-up oxygen. CSE Corporation subsequently discovered

    one SCSR that lacked sufficient start-up oxygen in that companys internal quality controlprogram and voluntarily stopped further production and sales of SR-100s.

    NIOSH developed a protocol to test for the presence of start-up oxygen in field-deployed SR-

    100s. The purpose of the test was to determine if the failure rate of the start-up oxygen in the

    population of 70,000 field-deployed units exceeded 1%. NIOSH and MSHA used American

    Society for Quality (ASQ), Sampling Procedures and Tables for Inspection of Isolated Lots byAttributes (ASQC Q3-1988)

    1. In assessing the SR-100s, if no more than 3 failures of start-up

    oxygen occurred in the 500-unit random sample, the SR-100 could be accepted as meeting the

    Limiting Quality (LQ) rate of 1.25% for start-up oxygen performance.

    NIOSH tested five hundred field-deployed devices collected from coal mines throughout theUnited States. NIOSH observed 5 start-up oxygen failures in the 500 units it tested. Themaximum number of failures allowed under the LQ rate of 1.25% was exceeded; therefore, the

    1% maximum allowable failure rate under the protocol was not met.

    1 American National Standard, Sampling Procedures and Tables for Inspection of Isolated Lots by Attributes,(ANSI/ASQC Standard Q3-1988), American Society for Quality, 1988.

    iii

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    Contents

    Executive Summary ........................................................................................................iiiContents ..........................................................................................................................ivAcronyms and Abbreviations ...........................................................................................viIntroduction ..................................................................................................................... 1Methods .......................................................................................................................... 2Results ............................................................................................................................ 4Major Findings ................................................................................................................. 9Appendix 1 .................................................................................................................... 10

    iv

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    Figures

    Figure 1. Age histogram of SR-100 population ....................................................................... 5Figure 2. Age histogram of targeted sample............................................................................ 5Figure 3. Age histogram of tested sample ............................................................................... 6

    Figure 4. Unit 154821 ...................................................................................................... 8Figure 5. Unit 154821 Dented bottom cover. ....................................................................... 8Figure 6. Unit 249530 .................................................................................................................. 8Figure 7. Unit 114752 .................................................................................................................. 8Figure 8. Unit 251475 .................................................................................................................. 9Figure 9. Unit 249607 .................................................................................................................. 9

    Tables

    Table 1. Inspection Failures ....................................................................................................... 6Table 2. Start-up oxygen failure details .................................................................................... 7

    v

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    Acronyms and Abbreviations

    ANSI American National Standards InstituteAQL Acceptable Quality Level

    ASMD Acoustic Solids Movement DetectorASQ American Society for QualityASQC American Society for Quality ControlCFR Code of Federal RegulationsLQ Limiting QualityLTFE Long-Term Field EvaluationMSHA Mine Safety and Health AdministrationNIOSH National Institute for Occupational Safety and HealthQA Quality AssuranceSCSR Self-Contained Self-RescuerS/N Serial NumberF Degrees Fahrenheit

    vi

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    Introduction

    The National Institute for Occupational Safety and Health (NIOSH) and the Mine Safety and

    Health Administration (MSHA) jointly approve respirators for use in the nations mines. Under

    42 CFR

    2

    84.3 (Respirators for mine rescue or other emergency use in mines), NIOSH andMSHA must jointly review and issue certificates of approval for respirators used for mine

    emergencies and mine rescue, which includes the CSE SR-100, a one-hour SCSR. At the time of

    this investigation, the SR-100 was one of three one-hour SCSR models used in the nationsmines.

    The SR-100 was approved in 1989 and has since been deployed in underground coal andmetal/nonmetal mines for use in emergency escapes. CSE classified the operation of the start-up

    oxygen as a Critical attribute. The regulation (in section 84.41) classifies potential defects as

    follows:

    (1) Critical. A defect that judgment and experience indicate is likely to result in a

    condition immediately hazardous to life or health for individuals using or depending upon

    the respirator;(2)Major A. A defect, other than critical, that is likely to result in failure to the degree

    that the respirator does not provide any respiratory protection, or a defect that reduces

    protection and is not detectable by the user;(3)Major B. A defect, other than Major A or critical, that is likely to result in reduced

    respiratory protection, and is detectable by the user; and

    (4)Minor. A defect that is not likely to materially reduce the usability of the respirator

    for its intended purpose, or a defect that is a departure from established standards and haslittle bearing on the effective use or operation of the respirator.

    To ensure the ongoing reliability of approved mine escape respirators, NIOSH and MSHAconduct a field testing program, referred to as the Long-Term Field Evaluation (LTFE), of

    SCSRs used in coal mines. Since 1982, the LTFE has identified reliability issues among the

    approved respirators stemming either from the environment or manufacturing. NIOSH notifiedCSE in December 2009 that two SR-100s exhibited little or no start-up oxygen during

    performance testing in the most recent phase of the LTFE. CSEs ensuing investigation

    identified excessive heat as a contributor to loss of start-up oxygen. However, the heat indicators

    on the failed units did not indicate prior exposure to excessive heat, suggesting a factor otherthan excessive heat was responsible for the loss of start-up oxygen.

    2 CFR. Code of Federal Regulations. Washington, DC: U.S. Government Printing Office, Office of the Federal

    Register.

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    During the ongoing investigation, CSE reported to NIOSH and MSHA that routine quality-

    assurance testing found an oxygen cylinder in a newly assembled SR-100 that contained aninsufficient quantity of start-up oxygen. CSE immediately and voluntarily ceased production

    and sales of the SR-100. CSE subsequently reinspected a large quantity of the pre-filled oxygen

    cylinders not yet installed in SR-100s. These oxygen cylinders had been previously confirmed to

    have oxygen volume sufficient for the start-up function. But upon reinspection, CSE foundbetween 0.5% and 1% of these pre-filled cylinder assemblies failed inspection due to oxygen

    volume loss.

    CSE engaged an engineering firm to analyze the loss of start-up oxygen. The engineering firm

    concluded that the loss of oxygen occurred at a threaded connection between the cylinder body

    and the stopper/outlet assembly. When asked to determine the percentage of affected, assembledSR-100s, CSE responded that it was less than 1% overall. CSE could not identify a systemic

    cause or otherwise confine the failure within certain lots. Therefore, the failure could exist

    among all field-deployed units.

    NIOSH developed a peer-reviewed protocol to evaluate a representative sample of field-deployed SR-100 respirators to determine the extent of the non-conformance. NIOSH andMSHA made a determination for coal-mine deployment that the failure of the start-up oxygen

    cylinder should be 1% or less in SR-100s deployed in U.S. coal mines. This criterion was based

    on MSHAs rules for coal mining requiring that each miner have an immediately available back-up unit.

    NIOSH and MSHA collected more than 500 SR-100s from coal mines throughout the country.

    NIOSH tested for low start-up oxygen cylinders from 500 units meeting the inspection criteria.The purpose of these tests was to determine if the failure rate of the start-up oxygen exceeded

    1% in the population of 70,000 field-deployed units. The remainder of this report describes themethods, results, major findings and the test protocol used for the investigation.

    Methods

    Sample Size Determination

    Information collected and provided by MSHA in its SCSRinventory3

    indicated approximately

    70,000 SR-100s were field-deployed during the time of this evaluation. A study protocol wasdeveloped that included a sampling strategy and a testing protocol (see Appendix I). The

    sampling plan was designed to detect with 95% confidence that the prevalence of cylinders with

    low start-up oxygen (i.e., failure rate) was less than 1.25% for a population of 70,000 units. Thesample selection plan was based on American National Standards (ANSI)/American Society of

    3 Further information may be found at http://www.msha.gov/forms/ELawsForms/2000-222.htm

    2

    http://www.msha.gov/forms/ELawsForms/2000-222.htmhttp://www.msha.gov/forms/ELawsForms/2000-222.htm
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    Quality (ASQC) Q3-1988, Sampling Procedures and Tables for Inspection of Isolated Lots by

    Attributes (Q3-1988), a quality assurance technique of sampling by attributes. The LimitingQuality (LQ) point nearest to and including the 1% criterion was selected from established tables

    with a sample size of 500 units. Three or fewer defective units would mean the failure rate for

    the population of 70,000 was less than or equal to 1.25% with 95% confidence.

    Recoverable Unit Criteria

    Each unit was assessed for compliance with manufacturer inspection criteria. The inspected

    characteristics assessed were the Acoustic Solids Movement Detector level (ASMD), moisture

    indicators, heat indicator, and several specific physical damage characteristics, which are

    grouped together and referred to as damage.

    The target sample size was set at 500 recoverable units (see Appendix 1). A recoverable unit

    was defined as a unit that could be located, would be relinquished by the owner, and passed allmanufacturer inspection criteria for use. Prior experience collecting respirators from mine

    service indicated that more than 500 units would need to be collected and assessed to achieve thedesired sample size. To adjust to difficulty encountered in collecting SR-100s, units werecollected and tested in two major phases. However, the testing procedure did not change from

    phase 1 to phase 2.

    Phase 1 Unit Collection and Testing

    Units were randomly selected by serial number from the full list of 70,000 deployed units

    consistent with the original protocol (see Appendix 1). Compensation was offered to mineoperators for any collected unit. Compliance with NIOSH/MSHA approval requires that

    owners/users of approved respirators abide by all manufacturer recommendations. Units passingall visual inspection and test criteria were considered recoverable and tested according to the test

    plan analysis described in the protocol (Appendix 1). Phase 1 collection and testing of SR-100s

    occurred over a period of 5 months.

    Phase 2 Unit Collection and Testing

    MSHA regulations established at 30 CFR 75.1714-4, promulgated under the Mine

    Improvement and New Emergency Response Act of 2006, Pub. L. 109-236 (S. 2803), Section 2

    (3)(C)(iii)(II), require coal mine operators to maintain specific quantities (multiple units perminer, per each operators approved Emergency Response Plan) of SCSRs to support mine

    escape. Operators were concerned that providing units for testing would result in noncompliance

    with MSHA requirements for SCSR coverage before replacement units became available, and

    were thus unwilling to provide units for NIOSH testing. As such, it was not possible to completethe collection and testing of SR-100s within a reasonable period of time, using a pure random

    collection method.

    NIOSH subsequently met with the original protocol peer reviewers to discuss the collection

    challenges and determine an alternate strategy. The reviewers agreed that little if any bias would

    be introduced if availability was the priority for collecting the remaining units. Availability, as

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    used here, indicates the units could be located and their owners were able to part with them

    through the NIOSH replacement offers. This protocol change allowed NIOSH to collectrecoverable units from coal mine operators who were able to part with their units and still meet

    MSHA backup unit requirements.

    NIOSH and MSHA identified two large mine operators who were in the process of withdrawingSR-100s on a mine-by-mine basis. Units were selected by obtaining the highest ranking serial

    numbered units in the randomized list of 70,000 deployed units. This resulted in sporadicconcentrations of production months, but the overall sample still spans the time period over

    which CSE produced SR-100s under the prevailing construction method. Similar to phase 1,

    collected units were inspected according to the manufacturer criteria. Phase 2 collection and

    testing of SR-100s occurred over a period of 3 months.

    Test Method

    Each recoverable unit was catalogued and photographed. The units were prepared for oxygen

    volume evaluation. The start-up oxygen volume was released, measured and compared to themanufacturers established QA criteria. Failure was determined when the volume of start-upoxygen released was less than the age-adjusted minimum volume defined in the CSE quality

    assurance plan (Appendix 1). This difference is noted as oxygen volume loss in Table 2.

    Results

    Age Distribution of Units

    Figures 1, 2, and 3 illustrate the manufacturing date frequency among the population at large

    (Figure 1), the targeted population (Figure 2), and the tested sample (Figure 3).

    A total of 137 SR-100s were collected in phase 1. One hundred and nine units were determined

    to be recoverable and subsequently tested, and 28 units were rejected due to one or more failures

    during inspection (see Table 1). No units were presented with failing moisture indicators, and

    few were presented with unacceptable amounts of physical damage.

    During the second phase of collection, units failing the manufacturers inspection criteria were

    rejected from inclusion in the oxygen starter study, but the reasons for rejection were no longeranalyzed or tallied. Three hundred ninety-one recoverable units were identified and tested

    according to the test plan.

    The study was not designed to evaluate the distribution and rate at which field-deployed units

    failed to meet the manufacturers standards for continued deployment.

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    0 5 10 15 20

    Nov-03

    Jun-04

    Jan-05

    Aug-05

    Mar-06

    Oct-06

    May-07

    Dec-07

    Jul-08

    Feb-09

    Sep-09

    Apr-10

    Percent of Units

    MonthofManufacture

    Population

    Figure 1. Age histogram of SR-100 population

    Targeted Sample

    Feb-04

    Aug-04

    Feb-05

    Aug-05

    Feb-06

    Aug-06

    Feb-07

    Aug-07

    Feb-08

    Aug-08

    Feb-09

    Aug-09

    MonthofManufacture

    0 5 10 15 20Percent of Units

    Figure 2. Age histogram of targeted sample

    5

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    Tested Sample

    0 5 10 15 20

    Percent of UnitsFigure 3. Age histogram of tested sample

    Feb-04

    Aug-04

    Feb-05

    Aug-05

    Feb-06

    Aug-06

    Feb-07

    Aug-07

    Feb-08Aug-08

    Feb-09

    Aug-09

    MonthofManufactur

    e

    Table 1. Inspection Failures

    Total

    Serial No.

    28 10

    4922

    11

    0284

    11

    1535

    11

    3083

    11

    6528

    11

    7030

    12

    0205

    12

    4293

    13

    0302

    13

    7049

    13

    7099

    13

    7613

    14

    5254

    14

    6851

    16

    8662

    18

    1851

    18

    7725

    18

    7902

    18

    9276

    19

    1208

    20

    2636

    14

    8400

    14

    8445

    20

    6317

    20

    9424

    22

    3677

    23

    1516

    23

    1542

    ASMD20

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    HeatIndicator 14 F

    ail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Fail

    Damage4 F

    ail

    Fail

    Fail

    Fail

    ASMD = Acoustic Solids Movement Detector

    137 units were inspected duringphase 1

    All recoverable units were tested according to the procedures outlined in the protocol (Appendix1). NIOSH observed five (5) failures among the 500 units tested (see Table 2).

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    Table 2. Start-up oxygen failure details

    Test Date

    Unit

    Serial

    Number

    Cylinde

    r Serial

    Number

    Manufacture

    Date

    Volume

    of

    Oxygen(liters)

    QA

    MinimumVolume

    Oxygen

    (liters)

    Oxygen

    Volume

    Deficiency(liters)

    Pass/

    Fail

    Age atTest Date

    (Months)

    Stored/

    Carried(Observation

    of current

    condition)

    02-08-11 154821 A68341 02-2007 3.97 6.4 2.43 Fail 48 Carried

    04-19-11 249530A18140

    206-2009 5.20 7.4 2.20 Fail 22 Carried

    04-19-11 114752 A20125 04-2005 0.02 6 5.98 Fail 72 Carried

    04-29-11 251475A18050

    3 08-2009 6.09 7.5 1.41 Fail 20 Carried

    05-17-11 249607A18131

    706-2009 0.93 7.4 6.47 Fail 23 Carried

    Overall, the failure discovery rate was 1 per 100 units examined. This rate was observed in both

    phases of collection, also suggesting the change in collection methodology did not affect theevaluation. One unit failed among the 109 tested from collection in phase 1, and 4 units failed

    among the 391 tested from collection in phase 2.

    The 500 tested SR-100s may be viewed as representing three sets of deployed units:(1) SR-100 units deployed at all coal mines using SR-100s (109 collected units, 1 failure

    detected),

    (2) SR-100 units deployed at coal mines operated by two targeted mining companies (391collected units, 4 failures detected), and

    (3) SR-100 units from the combination of sets 1 and 2 (500 collected units, 5 failures detected).

    The combined set (3) is considered to be representative of the population of all deployed units.

    Recoverable units were photographed prior to being opened for testing. Figures 4 through 9 arephotographs of the units with insufficient start-up oxygen. The photographs illustrate typical

    conditions of conforming fielded units. Many other tested units with sufficient start-up oxygen

    appeared to have incurred more wear and tear than the average failed unit.

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    Figure 4. Unit 154821 Figure 5. Unit 154821 Dented bottom cover.

    Figure 6. Unit 249530 Figure 7. Unit 114752

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    Figure 9. Unit 251475 Figure 8. Unit 249607

    Major Findings

    All of the units in which excessive start-up oxygen loss was observed had been carried for atleast some portion of their deployed lives, and exhibited typical conditions of conforming fielded

    units. While the unit with the largest total start-up oxygen loss was the oldest of this group, the

    next largest total loss measured was in one of the two newest units.

    NIOSH observed 5 start-up oxygen failures in the 500 units it tested. By the criteria set forth in

    the ASQC sampling tables, the target LQ of 1.25% is not met. The allowable failure rate of 1%

    established under the protocol is exceeded.

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    Appendix 1

    Protocol for Sampling, Testing and Analyzing Oxygen-Starter Performance of the

    CSE SR-100 Self-Contained Self-Rescuer

    Purpose:

    The purpose of this protocol is to establish procedures to sample, test, and analyze the CSE SR-

    100 Self-Contained Self-Rescuer (SCSR) oxygen starter performance in mine-deployed

    respirators.

    Background:

    The primary oxygen supply of the CSE, SR-100 SCSR is stored chemically. Upon activation, theSR-100 oxygen starter is designed to provide approximately 9 liters of gaseous oxygen into the

    breathing circuit of the SCSR. The injection of gaseous starter oxygen provides initial oxygen

    for breathing to allow time for the reaction in the chemical bed to activate and begin producingoxygen for the user. Tests performed as part of the National Institute for Occupational Safety

    and Health (NIOSH) Long Term Field Evaluation audit program in December 2009 and by the

    manufacturer as part of its quality assurance program, in February 2010, revealed failures ofoxygen starters on some units. CSE has calculated that the oxygen-starter failure rate on new

    units is less than one percent. CSE further reported to NIOSH and the Mine Safety and Health

    Administration (MSHA) that the oxygen starter failure is related to application of thread sealant

    and thread dimensions at the starter oxygen high-pressure valve connection and that the valveconnection assembly process is not traceable to a manufacturing lot or manufacturing date. The

    actual oxygen-starter failure rate in field-deployed units is not well characterized at this time.

    Based on certification performance requirements established at 42 CFR pt. 84, NIOSH andMSHA have determined that only a fully functioning oxygen starter enables performance of the

    SR-100 to be operationally compliant. Starter oxygen is required for proper function in the first

    several minutes of use and to ensure a complete oxygen supply. The 42 CFR pt. 84, samplingplans for addressing quality characteristics and the associated manufacturing process accepted

    quality levels (AQLs) are found at 42 CFR 84.41:

    84.41 Quality control plans; contents.(c) The sampling procedure shall include a list of the characteristics to be tested by the

    applicant or his agent.

    (d) The characteristics listed in accordance with paragraph (c) of this section shall beclassified according to the potential effect of such defect and grouped into the following

    classes:

    (1) Critical. A defect that judgment and experience indicate is likely to result in acondition immediately hazardous to life or health for individuals using or depending upon

    the respirator;

    (2)Major A. A defect, other than critical, that is likely to result in failure to the degreethat the respirator does not provide any respiratory protection, or a defect that reduces

    protection and is not detectable by the user;

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    (3)Major B. A defect, other than Major A or critical, that is likely to result in reduced

    respiratory protection, and is detectable by the user; and(4)Minor. A defect that is not likely to materially reduce the usability of the respirator

    for its intended purpose, or a defect that is a departure from established standards and has

    little bearing on the effective use or operation of the respirator.

    (e) The quality control inspection test method to be used by the applicant or his agent foreach characteristic required to be tested shall be described in detail.

    (f) Each item manufactured shall be 100 percent inspected for defects in all criticalcharacteristics and all defective items shall be rejected.

    (g) The Acceptable Quality Level (AQL) for each major or minor defect so classified by

    the applicant shall be:

    (1)Major A. 1.0 percent;(2)Major B. 2.5 percent; and

    (3)Minor. 4.0 percent.

    According to the NIOSH/MSHA approved quality plan, CSE defines the supply of starter

    oxygen for the SR-100 as a critical attribute. The expected failure rate of critical attributes iszero. Test data provided by CSE indicate the actual failure rate to be around one percent.Redundancy in deployment of SCSRs required under 30 CFR 75.1714-4, promulgated under

    the Mine Improvement and New Emergency Response Act of 2006, Pub. L. 109-236 (S. 2803),

    Section 2 (3)(C)(iii)(II), helps to offset any negative impact from unexpected performanceproblems and in this situation is being relied upon as a temporary solution. In a user notice

    offered by CSE on May 10, 2010, CSE acknowledged the benefit of redundancy in the event of

    oxygen starter failure, advising that, If for any reason a unit does not inflate the breathing bag,

    the user should don another unit if one is readily available. If a second unit is not readilyavailable, the manual start should be used. If an additional SCSR is readily available, the

    existing data showing a 1 in 100 (1%) failure rate would yield a 1 in 10,000 chance of havingboth units fail in any sequence of two SCSRs.

    As a permanent solution, CSE has proposed redesign of the SR-100, but as of the date of thisprotocol has not submitted plans to NIOSH and MSHA for approval test and evaluation.

    However, none of the improvements proposed thus far will address units currently deployed.

    Both NIOSH and MSHA expect that currently deployed SR-100s will ultimately need to bereplaced, and that the pace of the replacement needs to be driven by the actual oxygen-starter

    failure rate. To that end, a sampling of field-deployed SR-100s is proposed to determine the

    prevalence of failed oxygen starters in the CSE SR-100 respirators.

    Approach

    In order to properly establish the actual prevalence of failed oxygen starters among field-deployed SR-100s, NIOSH proposes using a quality assurance (QA) approach. Operation of the

    oxygen starter is a single quality attribute. Defined in this manner, standard QA sampling

    methods may be relied upon to yield a statistically significant characterization of the overallnumber of failures by the number of failures observed in a reasonably small sample. The total

    mine-deployed population of SR-100s currently exceeds 70,000 units, thus it is crucially

    important to draw upon widely recognized sampling techniques and statistical methods. While

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    the method proposed is not designed to find the actual proportion of failed starters, it will with

    great certainty establish important limits. For example, it will not be possible to state the failurerate is 0.8%, but it will be possible to state the failure rate does not exceed 1.25%, at a 95%

    confidence interval. The criteria selected are based around limits of 1.25%, 5%, 8%, and 12.5%.

    Criteria

    The SR-100 sample selection plan is based on American National Standards (ANSI)/AmericanSociety of Quality (ASQC) Q3-1988, Sampling Procedures and Tables for Inspection of Isolated

    Lots by Attributes (Q3-1988). NIOSH regulation 42 CFR 84.43 lists Mil-Std-105D as an

    acceptable sampling plan. Mil-STD-105D, as well as the now more widely used ANSI Z1.4,

    provides for sampling by Limiting Quality (LQ) levels when the actual consumer risk is at issue.The Q3-1988 is a recognized standard for LQ sampling plans. Q3-1988 plan offers LQ rates for

    0.5%, 0.8% and 1.25% nominal limiting quality. It also offers higher LQ rates up to 32%. An

    LQ rate of 1.25% represents a 95% confidence level that the lot will have less than 1.25% for thetested characteristic. Thus, a LQ value of 1.25% is a reasonable approximation of a 1%

    consumer risk defect level.

    To evaluate deployed SR-100 units for sufficient starter oxygen, NIOSH proposes to use Q3-

    1988 Limiting Quality (LQ) values. As noted, Q3-1988 lists standard tables of LQ quality levels

    ranging from 0.05 to 32 percent for various lot sizes. For a quantity of 35,000 to 100,000deployed SR-100 respirators and LQs ranging from 1.25 to 12.5, the proposed sampling criteria

    are:

    For LQ 1.25 the sample size is 500 pieces, accept on 3 defects, reject on 4 defects. D=0.27

    For LQ 5.0 the sample size is 500 pieces, accept on 18 defects, reject on 19 defects. D=2.5For LQ 8.0 the sample size is 315 pieces, accept on 18 defects, reject on 19 defects. D=3.9

    For LQ 12.5 the sample size is 200 pieces, accept on 18 defects, reject on 19 defects. D=6.3Where D = process average percent nonconforming.

    Accept means that the lot is determined to be within the LQ, reject means that the lot defect rateexceeds the LQ.

    LQ means that there is a 95% probability that the actual lot quality is equal or better than thestated requirement (1.25%). The process average (D), which corresponds to an AQL value, must

    be significantly better than the LQ in order to have a 95% probability of acceptance.

    With the Q3-1988 plan and a 500-piece SR-100 sample size, information at LQs of 2.0 and 3.15can also be obtained. For LQ 2.0 accept criteria is not more than 5 defects and for LQ 3.15

    accept criteria is not more than 10 defects.

    Sample Collection

    NIOSH will use the current MSHA SCSR inventory of all mine-deployed SR-100 units to

    randomize units manufactured after October 2003. The significance of October 2003 relates tosimilarity in design and construction. This is the date when the threads on the SR-100 starter-

    oxygen bottle were modified to the current design. The heat-exposure indicator was also added

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    to the SR-100 in that timeframe. (Fewer than 4700 of the currently deployed SR-100s in service

    in mines are older than this cut-off.)

    Using the MSHA inventory, and the unit serial number as a unique identifier, all in-service SR-

    100s newer than October 2003, will be randomized. As defined in Q3-1988, a sample size of

    500 is needed to ascertain the target LQ values at the stated level of confidence (95%). Pastexperience collecting SCSRs from mine service indicates that more than 500 units will need to

    be assessed in order to obtain 500 recoverable units for testing. A recoverable unit is a unit thatcan be found and passes all manufacturer inspection criteria for use. There are numerous reasons

    that individual units may not be found. Foremost among the reasons is that a unit reported in the

    inventory can be damaged and removed from service between the time it is recorded and the time

    that it is searched for in the collection. NIOSH will tabulate and organize the randomly selectedunit serial numbers by MSHA District and request each District to retrieve the SR-100s on its

    respective list. All units not recoverable shall be noted as such on the sample inventory list

    provided to the Districts, and the reason for which they are deemed to be unrecoverable shallalso be made part of that record. NIOSH will then retrieve units from the MSHA Districts.

    The ultimate goal of the collection is to assemble the lowest-ordered-500 randomly-listed,recoverable units available for testing. Since the logistics of sample collection and retrieval are

    not trivial, NIOSH proposes to accumulate these from the MSHA Districts in at least two forays

    to reduce the amount of over-selection needed to obtain the required sample. Units retrieved byNIOSH from the MSHA district offices will be re-inspected in the NPPTL lab by a NIOSH

    technician and tested in an order that ensures the goal of the collection, mentioned above, is met

    in full.

    NIOSH also wishes to reserve the ability to evaluate the test results in the most efficient manner

    permitted under the QA sampling plan. For instance, if 19 defects were to be observed withinthe first 100 units tested, the sample collection, if it has not already been completed, and testing

    could be halted. In that event, the logic of the QA sample plan indicates the highest selected lot

    rejection criterion has been exceeded at the number of observations. We would not know whatthe actual prevalence is, but we would know that the QA percent defective exceeds 12.5%, and a

    replacement rate decision could be made on that basis. Appendix A details some critical

    sampling plan decision points based on the number of defects observed.

    Test Plan Outline

    1. Record the SR-100 unit serial number and date of manufacture.2. Determine the minimum allowable volume of starter oxygen based on unit date of

    manufacturer and CSE maximum allowable leakage rate.

    3. Open SR-100a. If unable to open put the unit aside and do not use for this evaluation.b. If the unit opens proceed to step 4.

    4. Record serial number of oxygen starter cylinder.5. Measure volume of starter oxygen available. The breathing bag will be removed

    from the unit and the unit connected to a spirometer and an electronic data

    recorder for the volume measurement.

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    6. Compare measured volume of starter oxygen available with the minimum

    allowable oxygen volume from step 2.7. Test result:

    a. If the volume of starter oxygen available is equal to or greater than () theminimum allowable starter oxygen the unit is an accept (PASS);

    b.

    If the volume of starter oxygen available is less than (

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    Attachment 1

    Condition Measured Defect

    Rate, R

    Effective Failure Rate

    w/redundancy

    A R 12.5% at least 1 in 100

    *A measured defect rate of 3% represents the approximate point at which the effective failure

    rate in any sequential selection of two units rises above 1 in 1000.

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    DHHS (NIOSH) Publication No. 2012-139

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